IR 05000285/1997013

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-285/97-13 on 970718

ML20198P315
Person / Time
Site:	Fort Calhoun
Issue date:	01/13/1998
From:	Stetka T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Gambhir S OMAHA PUBLIC POWER DISTRICT
References
50-285-97-13, NUDOCS 9801220073
Download: ML20198P315 (4)

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January 13, 1998 S. K. Gambhir, Division Manager Engineering & Operations Support Omaha Public Power District Fort Calhoun Station FC 2-4 Adm.

P.O. Box 399 Hwy,75 - North of Fort Calhoun Fort Calhoun, Nebraska 68023-0399 SUBJECT: RESPONSE TO NRC INSPECTION REPORT 50-285/9713

Dear Mr. Gambhir:

Thank you for your letter of November 3,1997, in response to our October 2,1997, letter and Notice of Violation concerning the inadequate valve stroking test program and the failure to issue condition reports We have reviewed your reply and find it responsive tothe concerns raised in our Notice of Violation. We will review the implementation of your corrective actions duringa future inspection to determine inat full compliance has been achieved and will be maintained.

Sincerely,

/ &W Thomas F. Stetka, Acting Chief Engineering Branch Division of Reactor Safety Docket No.: 50 285 License No.: DPR-40 Cc:

James W. Tills, Manager

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Nuclear Licensing Omaha Public Power District .

Fort Calhoun Station- FC 2-4 Adm. ~ '

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P.O. Box 399 -

Hwy. 75 -' North of Fort Calhoun - g Fort Calhoun, Nebraska 68023-0399 i

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Omaha Public Power District 2 James W. Chase, Manager Fort Calhoun Station P.O. Box 399 Fort Calhoan, Nebraska 68023 '

Perry D. Robinson, Esq.

Wnston & Strewn 1400 L Street, N.W.

Washington, D.C. 20005-3502 Chairman Washington County Board of Supervisors Blair, Nebraska 68006 Cheryl Rogers, LLRW Program Manager Environmental Protection Section Nebraska Department of Health 301 Centennial Mall, South k ' P.O. Box 95007 e Lincoln, Nebraska 68509 5007 i

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444 Sa# 1Nh 50ent Uni Qnaha, Netranha rol@#47 November 3,1997 LIC 97 0169 U.S. Nuclear Regulatory Commission A1TN: Document Control Desk Mail Station PI 137 Washingten, D.C. 20555

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References: 1. Docket No. 50 285 2. letter from NRC (A. T. Ilowell) to OPPD (S. K. Gambhir) dated October 2, 1997 SUBJECT: Reply to a Notice of Violation, NRC Inspection Report No. 50-285/97-13 The subject report (Reference 2) transmittcJ a Notice of Violation (NOV) resulting from an NRC inspection conducted June 30 through July 15,1997, at the Fort Calhoun Station (FCS). Attached is the Omaha Public Power District (OPPD) response to this NOV.

If you should have any questions, pie tse contact me.

Sin,cerely, i

S. Division Manager Engineering & Operations Support EPM / epm Attachment [ h/ ' j c: Winston and Strawn -

E. W. Merschoff, NRC Regional Administrator, Redi on IV L R. Wharton, NRC Project Manager W. C. Walker, NRC Senior Resident inspector

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LIC-97 0169 Page!

NOTICE OF VIOLATION f i.

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Omaha "ublic Power District Docket No. 50-285 Fort Calhoun Station License No. DPR-40 l t

i During an NRC inspection conducted on June 30 through July 18,1997, three violations of NRC requirements were identitled. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG 1600, the violadons are listed below:

A. Technical Specincation 5.5.2.2 requires, in part, that the safety audit and review committee -

composition shall have a senior vice prwident as the chairperson. Contrary to the above, the licensee

was conducting safety audit and review committee meetings since January 17,1997, without the senior vice president as the chairperson.

This is a Severity Level IV violation (Supplement I) (285/97013 01).  ;

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H. .10 CFR Part 50, Appendix B, Criterion XI, states, in part, that "[a] test program shall be established to assure that all testing required to demonstrate that structures, systems, and components will <

perform satisfactorily inser vice is identined and performed in accordance with written test procedures, which incorporate the requirements and acceptance limlfs contained in applicable design documents. j Contrary to the above, the established test program did not demonstrate that the component cooling ,

water outlet valves from the component cooling water / raw water heat exchanger (11C%4898/490B/ i 491H/492B) would perform satisfactorily in service. The quarterly inservice test was performed in a

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manner such that the outlet valve was always stroked open and closed immediately prior to the thned opening stroke test. Thb preconditioning of tl.c valve prior to its stroke test precluded an accurate assessment of its initial opening capability. ,

This is a Sev.rity Level IV violation (Supplemem I) (50 285/9713-02).

f C. 10 CFR Part 50, Appendix H, Criterion V, " Instructions, Procedures, and Drawings," states that

" activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."

Procedare SO R-2, " Condition Report and Corrective Action," Revision 4, requ'res origination of a condition report for the following'

"... equipment related events, documentation deficiencies, non-routine outside agency notificutfons, operational events, testing denciencies, security infractions, human performance errors, personnel safety issues, radiological occurrences, or other circumstances which impact or potentially impact _

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safe /or refleble operation of Fort Calhoun Station .... "

Contrary to the above, the licensee failed to originate a condition report for the following liccusce-identined deficiencies'

(1) Procedures S0-G-21, "Modincation Control," Revision 62, and PED GEI 56, " Configuration Change Closecut," P.evision 4. contained deficiencies that could potentially impact the safe operation of the plant. These procedures allowed design documentation to be inconsistent with

- Held installatloas for an extended period of time. .

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I* 1.lC-97 0169 Page 2 (2) The 4 way solenoid for Valve FC%1904C had been repleted wkh a different model valve during or after the original plant startup, but no engineering change notice or drawing change had been procemed to document the change.

This is a Severity Level IV violation (Supplement I) (50-285/9713 04).

QW Public Power District (OPPD) Resoonse As requested by Reference 2 only responses to violations B and C are being provided.

Violation B I. - Reason for the violatiett The cause of this violation is that the Inservice Inspection (ISI) program did not perceive the test toethodology twing used as being preconditioning. Preconditioning was perceived as some action that is taken intentionally to ensure that a component would pass its Inservice Test (IST). That is, some action tlat would likely mask the effects of likely modes of component degradation. Since these valves are ganged together so that both valves operate when one switch is wetivated and since these valves are frequently repositioned during normal plant operation, it seemed appropriate to test the valves by consistently measuring the stroke time of the "A valve" first and the "B valve" second. It is likely that consistent performance of the test and obsetvation of the resultant trended data would detect deterioration of valve performance caused by any credible mode of valve degradation, even on the valves that are consistently stroke timed on their second stroke. nus, the present test methodology was considered adequate to provide reasonable assurance that the valves would be able to perform their safety function.

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11. Corrective Steps Which Have Been Taken and the Results Achieved 1. A review of category B valves tested under the IST Program was performed to identify valves that are

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ganged together and to rr w how these valves are tested. This review identified 86 ganged IST vahes that are tested under five uirierent surveillance tests. Thes: valves were tested in t. fashion similar to the valves identified in this violation notice. That is, the valves were stroke timed one at a time and one of the valves was always stroked once by the test procedure before the timing stroke was performed.

2. - FCS Operations Management has communicated their concerns about the issue of preconditioning of components prior to testing to heighten the awareness of the persons responsible for test performance.

This has resulted in a critical evaluation of the test procedures and maintenance practices being perfonned at FCS to identify situations or actions that could be defined as preconditioning. As a result, six condition reports and numerous procedure changes are being processed to correct preconditioning issues.

III. Corrective Steos Which Will Be Taken -

'l. The five procedures identified above are being revised to eliminate preconditioning of the ganged valves by requiring simultaneous stroke timing of the ganged valves or splitting the test procedure so that the A-valve and the B valve of the ganged pair are tested tit different times by different test procedures. These procedure changes will be implemented prior to the next scheduled performance of each of the Surveillance Tests,;

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1. k -' ' ' Attachment i

• i LIC 97-0169

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2, A portion of the fourth quarter 1997 Engineering Support Personnel Generic Continuing Training will be '

devoted to the subject of preconditioning of components prior to testing. This will heighten the awareness of the entire FCS engineering staff to the need to prevent proceduralizing any activities that could result in preconditioning of components prior to testits This training will be completed by December 31,1997, IV.' Date When Full Camnllance Will Be Achieved OPPD is currently in full compliance.

Violation C

I. Reason for the Violation ,

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Contrary to the requirements of SO R 2, in the two examples cited the individuals responsible for determining if a Condition Report should be written judged that the conditions did not " impact or potentially impact safe and/or reliable operation of Fort Calhoun Station" and therefore did not generate the required condition repora. .

While the decision not to initiate the appropriate Condition Reports was consistent with management expectations at the time, OPPD recognizes that it was not in strict compliance wPh the cited codes and

. procedures.

II. Corrective Stens Which Have Been Taken and the Results Achieved 1, A Condition Report was generated to encompass the issues noted in the two examples cited in the Violadon.

2. Management expectations regarding Condition Report initiation have been conveyed through training, meetings and one-on-one conversations. This has resulted in an increase in the number of Level 6 Condition Reports since the time of these events.

3. Management's expectation that "A condition report shall be written as adverse conditions and weaknesses are identified during self assessments." is included in Fort Calhoun Station Guideline

(FCSG) 4. " Performance of Self Assessments " FCSG-4 clarifies that identified adverse conditions and weaknesses are to be documented in Condi; ion Reports. Self assessments conducted since the issuance of this guideline in August 1997 have incorporated this guidance.

'III, Corrective Steps Which Will Be Taken

' None IV. Date When Full Compliance Will Be Achieved OPPD is currently in full compliance.

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